People v. Seymour
2025 IL App (4th) 240646-U
Ill. App. Ct.2025Background
- Alexander Thomas Seymour was convicted by a jury of aggravated domestic battery (strangling his mother) and domestic battery stemming from an incident on April 11, 2022.
- During jury selection, the trial court failed to question one selected juror about their understanding and acceptance of Illinois Supreme Court Rule 431(b) principles, as required.
- The only two accounts of the alleged domestic violence were given by Seymour (defendant) and his mother Paula Seymour (victim); their young child A.S. was present but did not testify.
- Photographic evidence of the mother's injuries and testimony from an investigating officer corroborated the State's case.
- Seymour did not present any evidence in his defense and did not file a posttrial motion challenging jury selection.
- On appeal, Seymour argued plain error regarding the lack of questioning of one juror under Rule 431(b), asserting the error was prejudicial due to closely balanced evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court violate Rule 431(b) by failing to question a juror? | State conceded error; the trial court missed one juror but otherwise complied. | Seymour argued this failure constituted plain error. | Yes, error occurred; Rule 431(b) was violated. |
| Was the evidence at trial closely balanced such that the error was prejudicial? | State argued photographs and officer’s corroboration removed this from a mere credibility contest. | Seymour argued it was a contest of credibility and the corroborating photos were inconclusive. | Evidence was not closely balanced; extrinsic evidence favored State. |
| Was the error reversible plain error warranting a new trial? | State argued harmless error since evidence was not close. | Seymour argued the error was plain and prejudicial, requiring reversal. | No plain error; conviction affirmed. |
| Should failure to seek medical attention undermine victim's credibility? | State argued victim’s post-incident actions were consistent with her account. | Seymour argued lack of medical care undermined her credibility. | Victim's credibility not undermined by lack of medical treatment. |
Key Cases Cited
- People v. Zehr, 103 Ill. 2d 472 (Ill. 1984) (Rule 431(b) derives from this case, requiring juror understanding of certain principles)
- People v. Thompson, 238 Ill. 2d 598 (Ill. 2010) (clear Rule 431(b) mandates specific questions and responses from each juror)
- People v. Naylor, 229 Ill. 2d 584 (Ill. 2008) (plain error and closely balanced evidence standards)
- People v. Wilmington, 2013 IL 112938 (Ill. 2013) (plain error review process)
- People v. Sebby, 2017 IL 119445 (Ill. 2017) (how to assess closely balanced evidence)